16 (2)
Jennifer L. Hall
From:Mariaisabelle Garcia <mariaisabelleg@kennedycommission.org>
Sent:Tuesday, November 1, 2022 4:34 PM
To:Public Comment
Cc:PublicLands@hcd.ca.gov; Daisy Cruz; Cesar C; Rudibel Barbosa
Subject:\[EXTERNAL\] public comment 11/1/22
Attachments:Ltr_Item 15 11.1.2022.docx.pdf
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See attached public comment from The Kennedy Commission
--
Blessings,
MariaIsabelle Garcia
Kennedy Commission Community Organizer
mariaisabelleg@kennedycommission.org
1
November 1, 2022
Mayor Pro Tem Trevor O’Neil
Councilmembers
Housing Authority
City of Anaheim
200 S. Anaheim Blvd.
Anaheim, CA 92805
RE: Item 16 -INITIAL STUDY/MITIGATED NEGATIVE DECLARATION MITIGATION
MONITORING PLAN NO. 384 DEVELOPMENT APPLICATION NO. 2021-00123
Dear Mayor Pro Tem Trevor O’Neil and City Council Members:
The Kennedy Commission (the Commission) is a broad-based coalition of residents and
community organizations that advocates for the production of homes affordable for families
earning less than $20,000 annually in Orange County. Formed in 2001, the Commission has
been successful in partnering and working with Orange County jurisdictions to create effective
housing and land-use policies that has led to the new construction of homes affordable to lower
income working families.
As the City Council considers the approval of a General Plan Amendment, Reclassification,
Conditional Use Permit, Minor Conditional Use Permit, and Tentative Tract Map for the
proposed development at the southeast corner of Anaheim Boulevard and Ball Road, The
Kennedy Commission continues to urge the Council to not approve an agreement until the City
of Anaheim and Greenlaw Development commit to maximizing affordable housing production
on this city-owned land.
The City needs to prioritize developments that are 100% affordable for lower-income families on
this city-owned site to maximize and leverage additional federal and state housing funds,
especially land acquired by the Housing Authority or the city using lower-income housing funds.
At a minimum, 15%-20% of the units should be affordable to low, very low, and extremely
low-income families. We stated our opposition in the letter submitted for the first reading of the
project on October 27, 2020, November 10, 2020 (second reading), and the amendment to the
Exclusive Negotiation agreement on December 7, 2021.
As highlighted in the City of Anaheim’s latest Housing Element Annual Progress Report that
was submitted to the California Housing and Community Development department1, the city has
a deficit of affordable housing production. The report points out that the city has approved and
permitted over 8,719 housing units during the current Housing Element period and only 369
have been in the affordability level of low and very low income. The remaining
1 City of Anaheim, Housing Element Annual Progress Report, June 2022
Mayor Pro Tem Trevor O’Neil and City Council Members
November 1, 2022
RHNA for lower-income households is 1,794. The vast majority of the housing units, 8,350,
have been approved at moderate and above moderate-income levels (RHNA in above moderate
has been exceeded by over 300%). Given the City’s track-record of prioritizing moderate and
above-moderate housing on Housing Opportunity Sites, which were identified in the current
Housing Element as sites that can be used to meet the City’s RHNA requirements at the very-low
and low-income levels, the City will have a very difficult time meeting its current and upcoming
RHNA allocation.It is imperative that city-owned land is prioritized to develop
lower-income housing that is not being addressed by market rate development.
In disposing of city-owned land, the city should prioritize the creation of affordable housing for
low, very low, and extremely low families in compliance with the Surplus Land Act and
successor agency obligations. When disposing of publicly owned land, public agencies have an
obligation to comply with the Surplus Land Act or exemptions to the act. Herein the city is not
complying with the Surplus Land Act or its exemptions, wherein they are not providing a
minimum of 20% of units at low, very low, and extremely low-income levels.
The Commission looks forward to further conversations regarding the use of city-owned land to
increase affordable housing opportunities for lower-income families in Anaheim. Please keep us
informed of any updates and meetings regarding strategies to increase affordable homes for
lower-income households in the city. If you have any questions, please free to contact us at (949)
250-0909 or cesarc@kennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
cc: Ms. Megan Kirkeby, Acting Deputy Director, Housing Policy Development, CA HCD
Mr. Paul McDougall, Housing Manager, CA
HCD PublicLands@hcd.ca.gov
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